On both sides of the Atlantic, the net result is the same: a huge risk-avoidance endeavour which reflects the illusion that everyday life can be made almost perfectly safe.
With a focus first and foremost on reliability and avoidance of risk, it is generally the antithesis of a culture that thrives on new and revolutionary ideas.
Campaigners say such schemes exploit workers by putting them at risk of being chased for unpaid taxes and have described the practice as "abusive tax avoidance".